Privacy Policy of Securepoint GmbH - Mobile Security

I. Name and address of the controller

The controller in the context of the General Data Protection Regulation, other national data protection laws of EU Member States and other data protection regulations is:

Securepoint GmbH Bleckeder Landstraße 28 21337 Lüneburg Germany (headquarters) Telephone: 04131/2401-0

Email: datenschutz@securepoint.de

Website: https://www.securepoint.de

Managing Directors: René Hofmann

II. Name and address of the data protection officer

The controller's data protection officer can be contacted at:

Securepoint GmbH Data protection officer Bleckeder Landstraße 28 21337 Lüneburg Germany (headquarters) Telephone: 04131/2401-0

Email: datenschutz@securepoint.de

Website: https://www.securepoint.de

III. General notes on data processing

1. Scope of processing personal data

We process personal data of our users only to the extent that is necessary to provide a functional website as well as our content and services. Routine processing of our users' personal data occurs exclusively with each user's consent. Exceptions to this rule are cases in which consent cannot be obtained in advance for factual reasons and data processing is permitted by legal regulations.

2. Legal basis for processing personal data

Art. 6 Para. 1 (a) of the EU General Data Protection Regulation (GDPR) serves as the legal basis insofar as we obtain the concerned data subject's consent to process personal data.

Art. 6 Para. 1 (b) GDPR serves as the legal basis where data processing is necessary for the performance of a contract to which the data subject is party. This also applies in order to take steps at the request of the data subject prior to entering into a contract.

Art. 6 Para. 1 (c) GDPR serves as the legal basis where processing is necessary for compliance with a legal obligation to which our company is subject.

Art. 6 Para. 1 (d) GDPR serves as the legal basis when processing is necessary in order to protect the vital interests of the data subject or of another natural person.

Art. 6 Abs. 1 (f) GDPR serves as the legal basis where processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party and such interests are not overridden by the interests or fundamental rights and freedoms of the data subject.

3. Data erasure and storage duration

The personal data of data subjects is deleted or blocked as soon as the purpose of data storage no longer applies. Data storage beyond this purpose is permissible if provided for in EU regulations, laws or other Directives issued by the EU or national legislators to which the controller is subject. Data will also be erased or blocked on expiry of a storage period specified by the named standards, unless continued data storage is necessary for the purpose of contract conclusion or contract performance.

IV. Provision of the service and generation of log files

1. Description and scope of data processing

Our system automatically collects data and information from the requesting computer system every time our website is accessed. The following data are collected:

(1) Information about the browser type and version (2) The user's operating system (3) The user's internet service provider (4) The user’s IP address (5) Date and time of access (6) Websites referring the user to our website (7) Websites accessed by the user via our website

These data are also stored in our system's log files. These data are not stored together with other personal data of the user.

2. Legal basis for processing data

Art. 6 Para 1 (f) GDPR is the legal basis for temporary data and log file storage.

3. Purpose of data processing

Interim storage of the IP address by the system is necessary in order to grant the user's computer access to the website. The user's IP address has to be stored for the duration of the session.

It is stored in log files to ensure the website's functionality. Additionally, we use the data to optimise our website and ensure the security of our IT systems. Data are not processed for marketing purposes in this context.

These purposes reflect our justified interest in data processing pursuant to Art. 6 Para. 1 (f) GDPR.

4. Duration of storage

Data are deleted as soon as they are no longer required for the purpose for which they were collected. In the context of collecting data to make the website available to the user, this is the case when the session is terminated.

In the context of storing data in log files, this is the case after a maximum of 35 days. Data may be stored beyond these time periods. In this event the users' IP addresses are erased or alienated so that an allocation of the requesting client is no longer possible.

5. Objection and elimination options

Collecting data to make the website accessible and storing data in log files are essential to the website's operation. Users therefore have no option to object.

V. Provision of the Mobile Security service

1. Description and scope of data processing

Our system automatically collects data and information from the accessing device every time the Mobile Security service is used. The following data are collected:

(1) Name, telephone number and email address of the user (2) Information about the device and the version used (3) The mobile device's operating system (4) The user's internet service provider (5) The user’s IP address (6) Date and time of access (7) Websites referring the user to our website (8) Websites accessed by the user via our website (9) Email addresses as well as incoming and outgoing telecommunication data (10) Device type (Android/Apple IOS), device ID and serial number, manufacturer and model of the mobile device, IMEI number (11) Network operator, provider, tariff (12) Bluetooth MAC address and Wi-Fi MAC address (13) Roaming status (14) User (15) Profile (16) VPN end point (17) Contract data, customer number, contract number, invoice number, inventory link, store account status, description, handover, effective time and date of contract data: purchased on, contract concluded on, contract duration, warranty period, invoice date, warranty start date. (18) Applications (19) General: Date of the request, key for the device, VPN, Tenant ID (20) HTTP: URL, block action, category, target IP, country of the target IP, response/request size, status code, MIME type (21) VPN: Dial-up, registration, client IP, UTM of the action (22) Virus scanner: Reason for the action, action, size, URL (23) Warnings: Key for the device, VPN, tenant ID, alert ID, event date, alert date, email recipient

These data are also stored in our system's log files. These data are not stored together with other personal data of the user.

2. Legal basis for processing data

Art. 6 Para. 1 (a) of the EU General Data Protection Regulation (GDPR) serves as the legal basis insofar as we obtain the concerned data subject's consent to process personal data.

Art. 6 Para. 1 (b) GDPR serves as the legal basis where data processing is necessary for the performance of a contract to which the data subject is party. This also applies in order to take steps at the request of the data subject prior to entering into a contract.

Art. 6 Para. 1 (c) GDPR serves as the legal basis where processing is necessary for compliance with a legal obligation to which our company is subject.

These purposes reflect our justified interest in data processing pursuant to Art. 6 Para. 1 (f) GDPR. Art. 6 Para 1 (f) GDPR is the legal basis for temporary data and log file storage.

3. Purpose of data processing

Data are stored on an interim basis to protect the device and the network into which the device is logged in from viruses and malware, as well as from racist, discriminatory, pornographic or politically extreme content and other content that poses a threat to the protection of minors or is illegal or in violation of legislation or other regulations.

Interim storage of the IP address by the system is necessary in order to grant the user's computer access to the website. The user's IP address has to be stored for the duration of the session.

It is stored in log files to ensure the device's functionality. Additionally, we use the data to optimise our website and ensure the security of our IT systems. Data are not processed for marketing purposes in this context.

4. Duration of storage

Data are deleted as soon as they are no longer required for the purpose for which they were collected.

In the context of storing data in log files, this is the case after a maximum of 35 days. Data may be stored beyond these time periods. In this event the users' IP addresses are deleted or alienated so that an allocation of the requesting client is no longer possible.

5. Objection and elimination options

Collecting data to make the website accessible and storing data in log files are essential to the website's operation. Users therefore have no option to object.

VI. Use of cookies

1. Description and scope of data processing

Our website uses cookies. Cookies are text files that are stored in the internet browser or on the user's computer system by the internet browser. A cookie can be stored on the user's operating system when he visits a website. This cookie contains a characteristic sequence of characters that enable the clear identification of the browser during a subsequent visit to the website.

We use cookies to make our website more user-friendly. Some of the elements of our website make it necessary to render the accessing browser identifiable after a change of website.

The following data are stored in and transferred by the cookies:

(1) Language settings (2) Login information

2. Legal basis for processing data

Art. 6 Abs. 1 (f) GDPR is the legal basis for processing personal data in conjunction with the use of technologically necessary cookies.

Art. 6 Abs. 1 (a) GDPR is the legal basis for processing personal data in conjunction with the use of cookies for analytical purposes given the corresponding consent of the user.

3. Purpose of data processing

The purpose of using technologically essential cookies is to make it easier for users to use the website. Some of the functions of our website cannot be used without cookies. These cookies require the browser to remain recognisable after a change of website.

We need to use cookies for the following applications listed in the following. Examples can include:

(1) Adopting language settings (2) Noting search terms

User data collected by technologically essential cookies are not used to compile user profiles.

Our justified interest in processing personal data pursuant to Art. 6 Para 1 (f) GDPR also lies in these purposes.

4. Duration of storage, objection and elimination options

Cookies are stored on the user's computer and transmitted to our website from there. You as the user therefore have full control over the use of cookies. You can deactivate or restrict cookie transmission by changing the settings in your internet browser. Cookies that have already been stored can be deleted at any time. This can also occur automatically. Deactivating cookies for our website may render some of its functions unusable to the full extent.

VII. Registration

1. Description and scope of data processing

During the registration process we offer users an opportunity to register by entering personal data. The data are entered into an input mask and then sent to and stored by us. Personal data are not disclosed to third parties. The following personal data are collected during the registration process: user name, company, salutation, first name, surname, address, email address, telephone number.

In addition, the following data are collected at the moment of registration:

(1) The user's IP address (2) Date and time of registration

The user's consent to processing these data is collected during the course of the registration process.

2. Legal basis for processing data

Art. 6 Abs. 1 (a) GDPR is the legal basis for processing personal data in conjunction with the corresponding consent of the user.

If registration serves the purpose of pre-contractual measures or the performance of a contract to which the user is party, then Art. 6 Para. 1 (b) GDPR also serves as a legal basis for data processing.

3. Purpose of data processing

User registration is required to gain access to certain content and services offered through our website.

4. Duration of storage

Data are deleted as soon as they are no longer required for the purpose for which they were collected.

This is the case with data collected during registration if the user's registration with our website is cancelled or changed.

5. Objection and elimination options

You as the user are able to cancel registration at any time. You can have the data about your person held in storage changed at any time.

VIII. Provision of the Mobile Security BYOD service

1. Description and scope of data processing

The data entered into the input mask during the device registration process are transmitted to and stored by us. These data are:

(1) User name (2) Company (3) Salutation (4) First name (5) Surname (6) Address (7) Email address (8) Telephone number (9) Device ID (10) Device type (Android/Apple IOS) (11) Mobile device model (12) Manufacturer (13) IMEI number (14) Operating system of the mobile device (15) Serial number (16) Telephone number (17) Network operator (18) Bluetooth MAC address (19) Wi-Fi MAC address (20) Roaming status (21) Store account status

Our system automatically collects data and information from the accessing device every time the Mobile Security service is used. This is the telephone number in each case. These data are also stored in our system's log files. Statistical searches, location detection and data evaluation, however, are not possible for private devices.

2. Legal basis for processing data

Art. 6 Para. 1 (a) of the EU General Data Protection Regulation (GDPR) serves as the legal basis insofar as we obtain the concerned data subject's consent to process personal data.

Art. 6 Para. 1 (b) GDPR serves as the legal basis where data processing is necessary for the performance of a contract to which the data subject is party. This also applies in order to take steps at the request of the data subject prior to entering into a contract.

Art. 6 Para. 1 (c) GDPR serves as the legal basis where processing is necessary for compliance with a legal obligation to which our company is subject.

These purposes reflect our justified interest in data processing pursuant to Art. 6 Para. 1 (f) GDPR.

6. Purpose of data processing

The data is stored for the purpose of confirming the consent to the use of the device and for the purpose of transmitting the data subject's rights in accordance with the GDPR. We process the personal data entered into the input mask for the purpose of contacting the relevant user. The required justified interest in data processing applies in addition when contact is made via email.

Data are also stored in order to protect the device and the network into which the device is logged in from viruses and malware, as well as from racist, discriminatory, pornographic or politically extreme content and other content that poses a threat to the protection of minors or is illegal or in violation of legislation or other regulations.

7. Duration of storage

Data are deleted as soon as they are no longer required for the purpose for which they were collected. In the context of storing data in log files, this is the case after a maximum of 35 days.

8. Objection and elimination options

Collecting data to make the service accessible and storing data in log files are essential requirements for the operation of Mobile Security. Users therefore have no option to object.

The user can withdraw his consent to the processing of his personal data at any time. Users who contact us by email can object to the storage of their personal data at any time. In such an event it will not be possible to continue a conversation.

The withdrawal of consent to data processing and storage can be declared in writing by sending a letter to the address stated in the preceding or by sending an email to: datenschutz@securepoint.

In this event all personal data stored in the context of establishing contact will be deleted. Reference is also made to Clause XI of data protection regulations.

IX. Location determination (Lost Mode)

1. Scope of processing personal data

When a device is set to "Lost Mode", it transmits its location (longitude, latitude and accuracy) to our company's servers. The following data are stored during this process:

Longitude Latitude

Please note that the software is run exclusively on our company's servers. The personal data of users are not stored anywhere else.

2. Legal basis for processing personal data

Art. 6 Para. 1 (f) GDPR is the legal basis for processing the personal data of users.

3. Purpose of data processing

Location data makes it possible to locate the device in the event it is lost, whereby Art. 6 Para. 1 (b) GDPR serves as the legal basis for processing personal data for the purpose of contract performance.

Art. 6 Para. 1 (a) of the EU General Data Protection Regulation (GDPR) serves as the legal basis insofar as we obtain the concerned data subject's consent to process personal data.

Art. 6 Para. 1 (b) GDPR serves as the legal basis where data processing is necessary for the performance of a contract to which the data subject is party. This also applies in order to take steps at the request of the data subject prior to entering into a contract.

Art. 6 Para. 1 (c) GDPR serves as the legal basis where processing is necessary for compliance with a legal obligation to which our company is subject.

4. Duration of storage

Data will be deleted as soon as Lost Mode is cancelled.

5. Objection and elimination options

The personal data of data subjects are deleted or blocked as soon as the purpose of data storage no longer applies. Data storage beyond this purpose is permissible if provided for in EU regulations, laws or other Directives issued by the EU or national legislator to which the controller is subject. Data will also be deleted or blocked on expiry of a storage period specified by the named standards, unless continued data storage is necessary for the purpose of contract conclusion or contract performance.

X. Establishing contact and contact by email

1. Description and scope of data processing

Our system automatically collects data and information from the requesting computer system every time our service is used. The following data are collected:

(1) Information about the browser type and version (2) The user's operating system (3) The user's internet service provider (4) The user's IP address (5) Date and time of access (6) Websites referring the user to our website (7) Websites accessed by the user via our website

These data are also stored in our system's log files. These data are not stored together with other personal data of the user.

2. Legal basis for processing data

Art. 6 Para 1 (f) GDPR is the legal basis for temporary data and log file storage.

3. Purpose of data processing

Interim storage of the IP address by the system is necessary in order to grant the user's computer access to the website. The user's IP address has to be stored for the duration of the session.

It is stored in log files to ensure the website's functionality. Additionally, we use the data to optimise our website and ensure the security of our IT systems. Data are not processed for marketing purposes in this context.

These purposes reflect our justified interest in data processing pursuant to Art. 6 Para. 1 (f) GDPR.

4. Duration of storage

Data are deleted as soon as they are no longer required for the purpose for which they were collected. In the context of collecting data to make the website available to the user, this is the case when the session is terminated.

In the context of storing data in log files, this is the case after a maximum of 35 days. Data may be stored beyond these time periods. In this event the users' IP addresses are deleted or alienated so that an allocation of the requesting client is no longer possible.

5. Objection and elimination options

Collecting data to make the website accessible and storing data in log files are essential to the website's operation. Users therefore have no option to object.

XI. Rights of the data subject

When we process your data, you are the data subject in the context of the GDPR and you have the following rights vis-à-vis the controller:

1. Right to information

You can obtain confirmation from the controller as to whether personal data concerning you are processed by us.

In the event your personal data are processed by us, you can obtain the following information from the controller:

(1) The purposes for which your personal data are processed; (2) The categories of personal data that are processed; (3) The recipients or categories of recipients to whom your personal data have been or will be disclosed; (4) The planned duration of storage of your personal data or, if concrete details cannot be provided in this regard, the criteria for determining the duration of storage; (5) The existence of a right to correction or deletion of your personal data; the right to restriction of processing by the controller or the right to object to data processing; (6) The right to complain to a supervisory authority; (7) All available information concerning the origin of the data if the personal data were not collected from the data subject; (8) The existence of automated individual decision-making, including profiling, pursuant to Art. 22 Paras. 1 and 4 GDPR and – at least in these cases – meaningful information about the logic involved as well as the implications and intended effects of processing for the data subject.

You have the right to obtain information as to whether the personal data relating to you are transferred to a third country or an international organisation. In this context you have the right to be informed of appropriate guarantees pursuant to Art. 46 GDPR in relation to the transfer of personal data.

2. Right to rectification

You have the right to obtain from the controller the rectification of inaccurate or incomplete personal data concerning you. The controller must make the corrections without undue delay.

3. Right to restriction of processing

You have the right to obtain from the controller restriction of processing where one of the following applies:

(1) the accuracy of the personal data is contested by you, for a period enabling the controller to verify the accuracy of the personal data; (2) the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead; (3) the controller of personal data no longer needs the data for the original processing purpose but you require them for the purpose of asserting, exercising or defending legal claims, or (4) you have objected to processing pursuant to Article 21 (1) GDPR pending the verification whether the legitimate grounds of the controller override yours.

If you have restricted the use of your personal data, it shall, with the exception of storage, only be processed with your consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.

If you have obtained restriction of processing pursuant to the preceding conditions, you will be informed by the controller before the restriction of processing is lifted.

4. Right to erasure

a) Deletion obligation

You have the right to obtain from the controller the erasure of personal data concerning you without undue delay and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies:

(1) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;

(2) you withdraw consent on which the processing is based according to point (a) of Article 6(1), or point (a) of Article 9(2) GDPR, and where there is no other legal ground for the processing;

(3) you object to the processing pursuant to Article 21(1) GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Article 21(2) GDPR;

(4) the personal data have been unlawfully processed;

(5) your personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject;

(6) the personal data have been collected in relation to the offer of information society services referred to in Article 8(1) GDPR.

b) Disclosing information to third parties

Where the controller has made the personal data public and is obliged pursuant to paragraph Article 17 Para. 1 GDPR to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, those personal data.

c) Exceptions

The right to erasure shall not apply to the extent that processing is necessary:

(1) for exercising the right of freedom of expression and information;

(2) for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;

(3) for reasons of public interest in the area of public health in accordance with points (h) and (i) of Article 9 (2) as well as Article 9 (3) GDPR;

(4) for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89 (1) GDPR, in so far as the right referred to in paragraph a) is likely to render impossible or seriously impair the achievement of the objectives of that processing; or

(5) for the establishment, exercise or defence of legal claims.

5. Right to notification

The controller shall communicate any rectification or erasure of personal data or restriction of processing carried out in accordance with GDPR provisions to each recipient to whom your personal data have been disclosed, unless this proves impossible or involves disproportionate effort.

The controller shall inform you about those recipients at your request.

6. Right to data portability

You have the right to receive the personal data concerning you, which you have provided to a controller, in a structured, commonly used and machine-readable format. You also have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where:

(1) the processing is based on consent pursuant to point (a) of Article 6 (1) GDPR or point (a) of Article 9 (2) GDPR or on a contract pursuant to point (b) of Article 6 (1) GDPR; and

(2) the processing is carried out by automated means.

In exercising your right to data portability, you also have the right to have the personal data transmitted directly from one controller to another, where technically feasible. The right referred to shall not adversely affect the rights and freedoms of others.

The right to data portability shall not apply to the processing of personal data necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

7. Right to object

You have the have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on point (e) or (f) of Article 6 (1) GDPR, including profiling based on those provisions.

The controller will then no longer process your personal data unless he demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms or if processing serves the establishment, exercise or defence of legal claims.

Where personal data are processed for direct marketing purposes, you have the right to object at any time to processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.

If you object to processing for direct marketing purposes, your personal data will no longer be processed for such purposes.

In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, you may exercise your right to object by automated means using technical specifications.

8. Right to withdraw your data protection consent declaration

You have the right to withdraw your consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. If you wish to have your personal data corrected, blocked or deleted or if you wish to obtain information about your personal data held in storage or if you have questions concerning the collection, processing or use of your personal data or wish to withdraw your consent, please write to the following email address: datenschutz@securepoint.de.

9. Automated individual decision-making, including profiling

You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. This does not apply if the decision:

(1) is necessary for entering into, or performance of, a contract between you and a data controller; (2) is authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests; or (3) is based on your explicit consent.

Decisions referred to in the preceding shall not be based on special categories of personal data referred to in Article 9 (1) GDPR, unless point (a) or (g) of Article 9 (2) GDPR applies and suitable measures to safeguard your rights and freedoms and legitimate interests are in place.

In the cases referred to in points (1) and (3), the data controller shall implement suitable measures to safeguard your rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express your point of view and to contest the decision.

10. Right to complain to a data protection authority

Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of personal data relating to you infringes the GDPR.

The supervisory authority with which the complaint has been lodged shall inform the complainant on the progress and the outcome of the complaint including the possibility of a judicial remedy pursuant to Article 78 GDPR.